, unless the transaction poses “an elevated risk of illicit finance.” The U.K. government added that unhosted wallets could be used for a variety of legitimate purposes, including asan additional layer of protection as is sometimes the case for cold wallets.
“There is not good evidence that unhosted wallets present a disproportionate risk of being used in illicit finance,” said the HM Treasury report. “Nevertheless, the government is conscious that completely exempting unhosted wallets from the Travel Rule could create an incentive for criminals to use them to evade controls.”
The U.K. government made the change in response to a consultation between July and October 2021 from “[Anti-Money Laundering] /[Counter-Terrorism Financing] supervisors, industry, civil society, academia and several government departments,” in which many expressed concerns about the “breadth of personal information collected” around transfers to unhosted wallets as well as the time required to enact such policy.
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